A. Firm and Principal Owners
Heirloom Investment Management LLC (“HIM” or “the Advisor”) is a privately-held investment advisor
founded in 2015. It is a Delaware Limited Liability Corporation, and is owned by Heirloom Holdings, a Cayman
Islands based holding company that is in turn owned 100% by Geoff Dover. Heirloom Holdings also wholly-
owns subsidiaries in Canada, USA, UAE and Cayman Islands. These subsidiaries include voting, non-
participating shares in Heirloom Investment Fund SPC, Fidelis US Investment Co Ltd., and Heirloom Helicopter
Leasing Pool 2020 LLC, each of which are clients of the Advisor. These subsidiaries also include participating
shares in Heirloom Investment Fund SPC, as well as operating and holding company and investment
subsidiaries that are not investment advisory clients of the Advisor, but to which the Advisor may provide
non-investment advisory service work such as accounting, consulting or operational support.
Together these entities are known as the Heirloom Group.
B. Types of Services
I. AUM Services
HIM is an investment adviser registered with the SEC under the Investment Advisers Act of 1940
(“Advisers Act”).
HIM is an investment advisor offering primarily discretionary investment management services specialized in
niche alternative investments to certain clients (“AUM Advisory Clients”). All AUM Advisory Clients meet the
definition of Regulatory Assets Under Management. HIM’s specialty is in identifying, evaluating, structuring,
implementing and operating structures that benefit from either attractive long-term macroeconomic,
geopolitical or socioeconomic trends, or from market dislocations.
HIM primarily offers its services by creating, sponsoring and advising comingled vehicles and pooled funds
(“Funds”). These Funds may either provide access to a diversified portfolio of investments, or to a single
investment or investment strategy or theme.
All of HIM’s AUM Advisory Clients are “accredited investors” as defined under Rule 501 of the Securities Act
of 1933, as amended and “qualified purchasers” as defined under Section 2(a)(51) of the Investment
Company Act, as amended.
As of December 31, 2023, HIM had 5 AUM Advisory Clients, of which 4 operated on a discretionary basis, with
1 operating on a non-discretionary basis.
II. AUA Services
HIM also offers non-discretionary advisory services
to individuals, family offices, or corporations or other
holding entities owned by them (“AUA Advisory Clients”). Such services do not qualify as Regulatory Assets
Under Management. The scope of such advisory services are tailored to each client, and may include non-
discretionary advice on portfolio construction, asset allocation, individual investment selection or due
diligence, investment reporting, family office structuring and operation, or other items related to the
operation of an investment portfolio.
All of HIM’s AUA Advisory Clients are “accredited investors” as defined under Rule 501 of the Securities Act of
1933, as amended. As of December 23, 2023, HIM had 4 AUA Advisory Clients.
C. Bespoke Service Offering
HIM tailors its service offering to the needs and requirements of each client.
For AUM Advisory Clients, HIM typically is delegated investment selection, evaluation, structuring and
management, as well as portfolio construction, and risk management responsibilities. In certain
circumstances such clients may have input into these processes or may delegate these to HIM to exercise at
its discretion within a specified framework. Most AUM Advisory Clients also delegate partial operating
responsibilities to HIM, often liaising with and/or overseeing other external service providers engaged by the
client, such as financial auditors, administrators, AML service providers, custodians, etc.
AUA Advisory Clients typically have a large degree of customization of services provided by HIM. These
services can include advising on governance structures, undertaking a portfolio review, conducting due
diligence on a specific investment opportunity, undertaking investment reporting, sitting on Investment
Committees, etc. The services are determined based on each client’s needs and existing resources.
D. Wrap Fee Programs
HIM does not participate in, nor does it offer, wrap fee programs.
E. Assets Under Management
As of December 31, 2023, HIM had $123mm in regulated assets under management related to AUM Advisory
Clients, of which $77mm were managed on a non-discretionary basis, and $46mm were managed on a
discretionary basis.
In addition, on December 31, 2023, HIM had $236mm in assets related to AUA Advisory Clients on which it
advised pursuant to advisory services that do not qualify as regulated assets under management.